When attaching exhibits, only attach the relevant portion of a lengthy exhibit. On occasion we receive a 250 page deposition attached as an exhibit to a motion for summary judgment, with only a handful of excerpts from the deposition actually cited in the motion. When fil- ing a motion with exhibits, the lawyer should try to attach only the relevant por- tions of deposition transcripts, as well as a few surrounding pages for context. At- taching a 250 page deposition when only 20 pages are relevant to the motion can distract from the consideration of the por-


tion of the transcript the lawyer seeks to bring to the court’s attention.


Respect motion practice deadlines. Law clerks often are confronted with a situation in which a motion has been filed, but the adverse party fails to file an opposition within the time line required by the Maryland Rules. Maryland Rule 2-311(b) reads: “a party against whom a motion is directed shall file a response within 15 days after being served with the motion . . . If a party fails to file a response required by this section, the


court may proceed to rule on the mo- tion.” (emphasis added). Rule 1-203 goes on to provide the lawyer with the method for computing the time in which a re- sponse will be due. If, for some reason, the lawyer cannot respond to a motion within the time mandated by the rules, the lawyer, under Rule 1-204(a)(2), must file a motion requesting the court to “ex- tend the period if the motion is filed before the expiration of the period origi- nally prescribed or extended by a previous order . . .”


Spring 2001


Trial Reporter


15


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